As you may be aware, the US enacted anti-hybrid rules on 22 December 2017. The anti-hybrid rules are found in section 267A of the Internal Revenue Code of 1986, as amended. The legislation grants the US Treasury Department and Internal Revenue Service (collectively, the “US Government”) with the authority to issue regulations as may be necessary or appropriate to carry out the purposes of the anti-hybrid rules. On 20 December 2018, the US Government exercised its authority by releasing proposed regulations under section 267A (the “Proposed Regulations”).
KPMG's Global Network of International Tax is pleased to invite you to a 60 minute webcast on 30 January 2019 that discusses the US anti-hybrid rules and the Proposed Regulations along with the following topics and their potential impact on non-US multinational organizations: